Reviewing a further sample of 107 CQC dental inspection reports published in November highlighted a number of compliance breaches and warnings which can easily be avoided, but which are still catching out some practices.
Of the 107 practices sampled, only 7 practices were issued with breach notifications, which is a big improvement on previous samples. Clearly the majority of practices are getting things right, which is great news. All notices reviewed this month were again issued for breaches within the “Well Led” standard, with just one other issued in respect of “Safe”.
It is very clear from this, and several previous samples, that the “Well Led” standards are still causing problems for many practices, despite most being fully compliant in the many other aspects of good practice management.
The “Well Led” standard is inspected under the following broad areas:
- Governance Arrangements (management structure and responsibilities/delegation)
- Leadership, Openness and Transparency
- Learning & Development/Continuous Improvement
- Seek and Act on Feedback from staff and the public/patients
In the spirit of continuous improvement and to try and help 100% of practices achieve a clean pass, here are some of the key-findings and recommendations from these very recent inspections, which might just keep another practice out of trouble.
Interesting to note that a number of the issues picked up by inspectors in recent reports have been flagged up in previous bulletins and all are easily resolved once identified.
- Don’t let the basic Infection Control procedures slip – remember that your Infection Control Audits and HTM01-05 should be at the forefront of everyone’s mind.
- Inspectors are still picking up evidence of audits being undertaken and filed with no subsequent action planning or attempt to resolve identified issues. Remember that once you have identified a risk, the practice is responsible for pro-actively resolving and/or reducing the risk to an acceptable level. Always document timescales, responsibility and follow-up plans.
- Medical Emergency procedures have caused problems for some practices. Remember to rehearse these regularly (keeping records), involve all staff, check that you have the essential drugs/equipment readily available as recommended by Resuscitation UK, British National Formulary, GDC and make sure that nothing in your emergency kit goes out of date.
- As with all policies and procedures, Safe-Guarding and Whistle-blowing procedures must be personalised to your own practice and reflect local contacts and procedures. Inspectors still find many examples of generic policies/procedures which bear no resemblance to what actually happens locally,
- Practices are still being picked up for inadequate recruitment procedures. Always follow simple, readily available checklists and procedures to demonstrate that you are doing things correctly and keep records readily available in staff files. This includes employment references, DBS certificate numbers, qualification certificates, photo i.d. and proof of residency/home address.
- Ensure you are receiving, checking and taking action on relevant MHRA/CAS patient safety alerts. Dental practices don’t receive many but there must be a robust system in place to show that you identify and respond to any that are published.
- Management of sharp injuries are regularly checked. Ensure procedures are in place and communicated to all the team. Endo files need to be risk assessed if used.
- Incident/Accident Reporting records must be updated for any significant events, including Sharps injuries..
- COSHH records not held or maintained/reviewed. Practices work with a lot of high-risk substances. Essential that you have information sheets and risk summaries for all, including routine cleaning materials. Immediate access to this information will be vital in the event of an accident. Also make sure that anything within your COSHH records is safely and securely stored to reflect the increased risk. Don’t forget to log and register those new materials you keep trying out if they are a COSHH risk.
- Make sure your clinical and domestic waste records are fully up to date and that appropriate waste audits have been completed accurately by yourself and your waste handlers.
- Check your drugs and materials for storage guidelines, ensure refrigerated where required and regularly check for out-of-date supplies.
- Make sure that your clinical team have up to date Hep B immunity records confirmed and available for checking, before working in risk areas. Take care to ensure all impacted staff have reached the minimum level of vaccine effectiveness.
- Inspectors continue to come across missing or partially-completed, mandatory risk assessments including Legionella, Sharps, Clinical Waste and COSHH. Make sure that any actions required to minimise risks are documented and implemented.
- Staff reviews/appraisals must be available to show evidence of performance, learning needs, “general well-being” and future training/development plans. Something is better than nothing, so don’t delay or wait for “perfection”. So often, inspectors are told that appraisals “are in hand” but not yet done.
- Interpretation services must be made available for patients who do not speak English, either in house or through an external third party service.
- Don’t forget to have an up to date Disability Discrimination Audit available along with plans for improvements or reasons why changes cannot reasonably be made.
- More practices are now making use of CCTV – make sure this is documented in your Data Protection records and that both staff and patients are given adequate notice of why CCTV is being used and that they have a right to view footage.
- Take care with “Off the Shelf” or “In a Box” Policy and Procedure packs. They are an essential and valuable source of material for many practices, but each policy/procedure must be reviewed and personalised to the practice and the way you work.
As always, remember that if something is not recorded or evidenced, in the eyes of the CQC and other external bodies such as the NHS, it didn’t happen, even though you may know full well that it did! This continues to catch practices out, leading to frustration and avoidable stress for all!
Findings from previous inspection reviews can be found here: CQC Hotspots
There is plenty of help out there to plug any management gaps including Your Dental Manager, so please do get in touch if you have any concerns or want to further improve the overall management/efficiency of your practice: firstname.lastname@example.org or check our on-line calendar to book a complimentary chat.